Jordan B. Wadle v. State of Indiana

Summary

The Indiana Supreme Court abandoned the constitutional statutory-elements and actual-evidence tests previously used for substantive double-jeopardy claims and adopted a statutory-interpretation framework. Under that framework, the court held that Wadle's convictions for leaving the scene of an accident, OWI causing serious bodily injury, OWI endangering a person, and OWI with a qualifying blood-alcohol concentration involved alternative rather than cumulative punishments. The court affirmed the sixteen-year sentence but ordered all convictions except the Level 3 felony leaving-the-scene conviction vacated.